Comments to the Army Corps of Engineers on the Raystown Lake Master Plan revision

Submitted to the Army Corps of Engineers by Laura Jackson, Vice President, on behalf of the Juniata Valley Audubon Society.

Map of the Lake Raystown area from the Huntingdon County Natural Heritage Inventory

To Whom it May Concern:

Please accept this letter as a formal comment submitted by the Juniata Valley Audubon Society, a chapter of the National Audubon Society, with over 300 members residing in Blair, Bedford, Huntingdon, Mifflin, and Centre Counties in central Pennsylvania. We appreciate the opportunity to provide comments to be considered in the development of the Raystown Lake Master Plan Revision.

Juniata Valley Audubon Society (JVAS) recognizes the diverse recreational resources offered by the Raystown Lake, its economic development potential, the importance of the flood control, and its clean hydropower. More importantly, however, we value the significant amount of relatively undisturbed habitat: approximately 18,000 acres (84%) of the Raystown Lake Project is forested. Since Terrace Mountain provides a forested backdrop to much of the eastern lake shore, we know that sustainable forest management is key to maintaining not only the viewscape, but the quality of water in Raystown Lake. We commend the US Army Corps of Engineers on their work to maintain this important habitat, so vital to maintaining clean water and healthy fish and wildlife.

Furthermore, we applaud the Corps' efforts to establish a Bat Conservation Area on Terrace Mountain in the Hawn's Bridge Peninsula area to maintain roosting and foraging habitat for northern long-eared bats and Indiana bats, as well as other forest dwelling bat species. JVAS supports managing these areas to mimic old growth conditions, which will create better habitat for roosting bats.

Another type of habitat quite different from the forested expanses are the rare shale barrens that occur in the Raystown Lake Project Area. We understand that the shale barren communities in Bedford and Huntingdon counties are one of the most unusual, and also most endangered, ecosystems in Pennsylvania. They are few in number and small in acreage, but contain endemic plant species found only in this habitat. The eleven shale barrens in the Raystown Lake Project are each significantly important since they vary in geographical and environmental features, as well as types of flora and fauna. We appreciate the Corps' dedication to protecting them by designating them as "Natural Areas," which will be preserved in their natural state.

We ask that the Corps continue to protect the shale barrens as designated Natural Areas by placing total restriction of any development in the area, and protecting the steep slopes and fragile environment of the barrens areas from disturbance, except for scientific investigation. Especially important is the restriction of foot travel on the slope and prohibition of watercraft docking at the base of the cliffs.

We are concerned, however, that the 9-acre shale barrens on the Hawn's Bridge Peninsula is under threat from future development. In the 1994 Master Plan, the Corps pledged complete protection and did not agree to any development on the Hawn's Bridge Peninsula. We know that the current Master Plan update is considering changing the use of this area. In keeping with the Corp's pledge to protect one of Pennsylvania's rarest and most endangered habitats, we would like to emphasize that this complete protection will only occur if the entire Hawn's Bridge Peninsula is protected from development. The 1994 master plan emphasized protection of the eastern shore, which includes the Hawn's Bridge Peninsula. We feel the eastern shore and Terrace Mountain should remain protected.

The Shale Barrens are also designated as part of the Raystown Biological Diversity Area (BDA), a Natural Heritage Area documented by the Western Pennsylvania Conservancy in the Huntingdon County Natural Heritage Inventory. Within the strata of BDAs, Huntingdon County recognizes Hawn's Bridge Peninsula to be the highest ranking: an "Exceptional Biological Diversity Area." See map at end of letter.

Our request to protect Hawn's Bridge Peninsula from development is supported by many local residents, including the Coalition to Protect Hawn's Peninsula. It is important to note that our request to protect Hawn's Bridge Peninsula is also aligned with the Huntingdon County Comprehensive Plan, 2007 Supplement. Sadly, the businesses and organizations that are promoting development of Hawn's Bridge Peninsula are at odds with the Comprehensive Plan.

Although it is not regulatory, the Comprehensive Plan is an important guiding document for Huntingdon County as it contains, "A Vision for the 21st Century." The Elements of the Vision include, "protection of farmland, forest land, natural resources, and the environment," while emphasizing new development "in and around existing boroughs and villages." It further emphasizes developing "greenways along rivers and ridges."

This vision is further detailed in this excerpt, " The vast majority of land in the County will remain in productive private rural land uses such as agriculture, forestry, and recreation. A system of “Greenways” will be established along mountain ridges, streams, and rivers to protect water quality, to provide habitat for wildlife, to enhance recreational opportunities, and to protect scenic beauty. "

One policy supported in this Vision does include, "the development of a year-round, full-service resort at Raystown Lake." However, we ask that such development should not be along mountain ridges such as Terrace Mountain, or impact rare habitats like shale barrens. Such a resort at Raystown Lake should be on Army Corps property where development already occurs, not in an exceptional Biological Diversity Area like Hawn's Bridge Peninsula.

In conclusion, Juniata Valley Audubon Society supports the protection of the eastern shore of Raystown Lake, specifically the endangered shale barrens which include the one located on Hawn's Bridge Peninsula. We request that Hawn's Bridge Peninsula be reclassified as an Environmentally Sensitive Area and that Terrace Mountain remain as a Low Density Recreation Area in the new Master Plan.